Richard Hamilton v. Randy Holderman
M2015-02302-COA-R3-CV
| Tenn. Ct. App. | Oct 27, 2016Background
- Richard and Nell Hamilton owned a furnished house and barn in Fentress County and rented it to Randy and Jennifer Holderman beginning November 2010; the parties disputed whether the arrangement was a sale or a rental.
- The Hamiltons sought possession in general sessions court; that court found the Holdermans were tenants, ordered them to vacate, and later awarded the Hamiltons $24,999.99 for conversion of personal property.
- The Holdermans appealed to the Fentress County Circuit Court; the Hamiltons sought $40,000 in conversion damages in that de novo jury trial and introduced prior testimony, photographs, and testimony about insurance coverage and item descriptions.
- The Holdermans counterclaimed for unjust enrichment, claiming they paid $32,100 toward an alleged purchase; the trial court denied directed verdicts and submitted conversion to the jury.
- A jury returned a $40,000 verdict for conversion and rejected the Holdermans’ unjust enrichment claim; the trial court entered judgment and the Holdermans appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for $40,000 conversion award | Hamiltons: owner testimony, photos, and increased insurance support $40,000 valuation | Holdermans: valuation not sufficiently proved; damages measure should be market value at time/place, not replacement/value-to-owner | Affirmed — material evidence supported the $40,000 award (owner valuation admissible; value-to-owner standard applies) |
| Remittitur request | Hamiltons: jury award supported; no remittitur needed | Holdermans: request remand with suggestion of remittitur to reduce award | Denied — court declines remittitur and upholds jury verdict |
Key Cases Cited
- Poole v. Kroger Co., 604 S.W.2d 52 (Tenn. 1980) (standard for appellate review of jury verdicts: material evidence test)
- Crabtree Masonry Co. v. C & R Constr., Inc., 575 S.W.2d 4 (Tenn. 1978) (appellate scope when reviewing jury verdicts)
- Miller v. Williams, 970 S.W.2d 497 (Tenn. Ct. App. 1998) (appellate court evaluates whether award is within reasonable range)
- Grandstaff v. Hawks, 36 S.W.3d 482 (Tenn. Ct. App. 2000) (duty to uphold jury verdict when supported by evidence)
- Adams v. Duncan Transfer & Storage of Morristown, 757 S.W.2d 336 (Tenn. Ct. App. 1988) (owner may testify to value of own property)
- Crook v. Mid-South Transfer & Storage Co., Inc., 499 S.W.2d 255 (Tenn. Ct. App. 1973) (household goods valued by "value to the owner" standard)
- Clift v. Fulton Fire Ins. Co., 315 S.W.2d 9 (Tenn. Ct. App. 1958) (discussing owner-based valuation for household items)
- Hohenberg Bros. Co. v. Mo. Pac. R.R. Co., 586 S.W.2d 117 (Tenn. Ct. App. 1979) (appellate court should not weigh evidence under material evidence review)
- Knoxville Traction Co. v. Brown, 89 S.W. 319 (Tenn. 1905) (definition of material evidence)